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ROTHENBERG v. COMMISSIONER

Docket No. 4585-64.

48 T.C. 369 (1967)

GEORGE ROTHENBERG AND BEATRICE ROTHENBERG, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 21, 1967.

Attorney(s) appearing for the Case

Harry Seiden, for the petitioners.

Rudolph J. Korbel, for the respondent.

OPINION

ATKINS, Judge:

The respondent determined a deficiency in income tax for the petitioners' taxable year 1961 in the amount of $49,257 and determined an addition to tax of $566.41 under section 6654 of the Internal Revenue Code of 1954 for underpayment of estimated tax. The respondent having conceded one of the issues herein, the only issue remaining for decision is whether the petitioners were entitled to elect to report gain on the sale of...

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